The need to reorganise ones affairs has moved out of the elite and into the mainstream. Groups of companies are becoming more common and therefore the need to rearrange them when circumstances change. This session aims to unpack the provisions of s 45 of the Income Tax Act and provide you with a working overview of the requirements.
After attending this course, delegates will have gained an understanding of the competencies mentioned below and must be able to apply the concepts and techniques in most situations and environments:
• Identify a valid s46 transaction
• Understand and identify the main risks when entering into a s 46 transaction
• Understand how the consideration must be treated in the contract.
• Understand and be able to account for all aspects of the transaction for tax purposes
• Understand the anti avoidance provisions
The aim of this session is to an answer to the following questions :
• What is an unbundling transaction?
• What are the requirements?
• Are there any anti avoidance provisions
• How does s46A impact this provision?
• What are the common pitfalls
• What are administrative requirements?
This course would be useful for all persons who provide tax advice for any clients. It would also be useful for any persons who are responsibility for the tax compliance of their businesses or their clients. Any delegate that is looking to get a refresher on the above topics would also be welcome.
